GuildHE welcomes proposals to better account for the intensity of study, which can vary significantly across and within providers. However, GuildHE has concerns with who exactly is counted as a student for the purposes of regulation.
The proposals would enable the OfS to charge providers significantly more, yet many of these students would receive no protections from being regulated by the OfS. There are also no incentives for providers who run courses but do not wish to have access to public funding, student loans or Tier 4 to register. These proposals complicate HE regulation further.
GuildHE’s full response can be read here.